The Compliance Deadline Every Australian Lawyer Needs to Know About

For decades, Australian lawyers have sat outside the country's anti-money laundering framework. Banks, casinos, and remittance providers have been obligated to monitor, report, and verify — but the legal profession has largely been exempt. From 31 March 2026, newly captured entities can enrol with AUSTRAC; from 1 July 2026, Tranche 2 obligations begin for practices providing designated services

From that date, Australia's anti-money laundering and counter-terrorism financing regime will capture new categories of professional activity, extending beyond traditional reporting entities such as banks, financial institutions, and casinos to include lawyers, accountants, real estate professionals, conveyancers, trust and company service providers, and dealers in precious metals and stones. These are the Tranche 2 reforms, and if you work in transactional or commercial law, they may apply to you, depending on whether your practice provides designated services.

What's Actually Changing

The reforms don't regulate lawyers as a profession in a blanket sense. The regime does not regulate "lawyers" as a profession; it regulates a subset of what they do. Whether a legal practice is inside or outside the AML/CTF net depends on whether the practice provides one or more designated services.

For commercial and transactional practitioners, those designated services are broad. They include assisting in the planning or execution of a transaction to sell, buy, or transfer a body corporate or legal arrangement; receiving, holding, controlling, or managing a person's property in connection with a transaction; assisting in organising, planning, or executing a transaction for equity or debt financing; and acting as or arranging for someone else to act as a director, secretary, attorney of non-natural persons, trustee, or partner.

Critically, AML/CTF obligations can arise before any of the above transactions occur, including during preparatory or organisational steps. Whether a matter is captured depends on whether it falls within a designated service, including certain transactional, corporate, trust, and asset-related activities.

The Key Dates

The compliance timeline is now very close:

• 31 March 2026: Enrolment opens with AUSTRAC for newly captured entities.

• 1 July 2026: AML/CTF obligations formally commence for Tranche 2 entities, including lawyers providing designated services.

Even one instance of providing a designated service requires you to enrol with AUSTRAC within 28 days. Obligations apply regardless of practice size. Sole practitioners are not exempt.

What You'll Need to Do

If you are a solicitor providing a designated service, you will need to conduct risk assessments to identify and understand the money laundering and terrorism financing risks specific to your practice; develop and maintain a written, risk-based AML/CTF compliance program; conduct customer due diligence before providing services; report certain transactions and suspicious matters to AUSTRAC; maintain identity verification and transaction records; and appoint a senior, Australian-based AML/CTF Compliance Officer with sufficient authority and independence to carry out compliance responsibilities.

For many commercial practices, the most immediate practical challenge will be client onboarding. Due diligence obligations mean verifying who your client actually is — and in some cases, who is behind them — before work begins. For high-volume transactional practices accustomed to fast turnarounds, that will require a genuine rethink of process.

What About Legal Professional Privilege?

It's a fair question, and one the profession raised loudly during the reform process. The new laws provide clearer protections for information or documents that are subject to legal professional privilege. Nothing in the amended Act affects the right of a person to refuse to give information or produce a document where that information or document would be privileged from production on the grounds of LPP. In practice, however, navigating the boundary between privileged advice and captured transactional work will require careful judgment.

Where to Start

If you haven't already mapped your firm's services against the designated services list, now is the time. The practical first step is to take a realistic look at what your practice actually does, compare it to the designated services, include one-off or low-volume services, and trace each service through to its real-world outcomes — asking whether it results in money moving, or an entity being created or ownership changing.

AUSTRAC has released Program Starter Kits designed specifically for small businesses in newly regulated sectors, including lawyers, which are customisable and have been endorsed by AUSTRAC as a tool to meet compliance obligations while reducing time and cost. For more complex practices, external compliance advice is worth the investment now — before 1 July, not after.

For further information, visit AUSTRAC's AML/CTF Reform page or contact your relevant state Law Society.